Therapists think SMART: #FightTheCuts – Rehab Realities


Renee kinder

November 2, the Centers for Medicare & Medicaid Services released final rule which includes updates on policy changes for Medicare payments under the Physician Fee Schedule (PFS) and other Medicare Part B issues, effective January 1, 2022.

The PFS Final Rule for calendar year 2022 is one of many rules that reflect a broader government-wide strategy to create a healthcare system that results in better accessibility, quality, affordability, empowerment and innovation.

How does this rule affect therapy services?

To begin with, CMS said they are completing the implementation of Section 53107 of the Bipartite Budget Act 2018, which requires CMS, through the use of new modifiers (CQ and CO), to identify and perform the 85% payment of Part B otherwise applicable. amount of payment for physiotherapy and occupational therapy services provided in whole or in part by physiotherapy assistants (PTA) and occupational therapy assistants (OTA) ─ when appropriately supervised by a physiotherapist (PT) or an occupational therapist (OT), respectively for the dates of service from January 1, 2022.

CMS defines services provided in whole or in part by PTAs or OTAs as those for which the PTA or OTA time exceeds a de minimis threshold.

Overall, the de minimis standard would continue to be applicable in the following scenarios:

· When the PTA / OTA independently provides a service, or a 15-minute unit of a “whole” service without the PT / OT providing part of the same service.

· In cases where the service is not defined in 15 minute increments, including: supervised modalities, assessments / reassessments and group therapy.

· When the PTA / OTA provides eight minutes or more of the final 15 minute unit of a billing scenario in which the PT / OT provides less than eight minutes of the same service.

· When the PTA / OTA and PT / OT each provide less than eight minutes for the final 15 minute unit of a billing scenario (10% standard applies).

In short, the The 15% payment differential is expected to take effect on January 1, 2022.

Additionally, as you all remember in the 2021 Medicare Physician Fee Schedule (MPFS) Final Rule, CMS has made changes to the Assessment and Management (E / M) Procedure Codes. in the office / outpatient clinic that resulted in increased payments for primary care services from 2021.

These increases would have resulted in significant reductions in reimbursements for therapists, as the CMS, by law, must ensure that the total values ​​of all procedure codes paid under the MPFS remain budget neutral.

Stakeholders have supported Congress’ efforts to significantly reduce these reductions in 2021.

However, full cuts will return in 2022 without further action from Congress to provide additional mitigation next year!

It’s time to think SMART – the “Medicare Rehabilitation and Therapy Access Stabilization Act” or the SMART Act.

On October 8, U.S. Representatives Bobby Rush (D-IL) and Jason Smith (R-MO) introduced the bipartisan Stabilizing Medicare Access to Rehabilitation and Therapy (SMART) Act of 2021 (HR5536), which provides for a temporary delay reduction in reimbursement CY 2022 Medicare Physician Fee Schedule.

The purpose of the bill is to protect beneficiaries’ access to therapy services by mitigating the impact of the impending 15% Medicare payment differential for services provided by physiotherapy assistants (PTAs) and physical assistants. occupational therapy (OTA) from January 1, 2022.

Specifically, the bill would delay the implementation date of the Medicare therapy assistant differential by 15% to January 1, 2023.

In addition, the bill would also support therapy assistants, many of whom live and work in minority and rural communities, by reducing the requirements for direct supervision of therapy assistants in private practices and aligning supervision with the requirements of the state; and provide an exemption to the differential for providers serving patients in rural and underserved areas.

These small changes to current policy would ensure unrestricted and timely access to therapy services for Medicare patients, especially those living in rural and underserved areas.

Now is the time to plead this issue as there is not much time left on the legislative calendar for Congress to act before this policy is implemented on January 1, 2022.

Ready to help ?

Good news!

The American Occupational Therapy Association (AOTA), the American Physical Therapy Association (APTA) and the American Speech Language Hearing Association (ASHA), in addition to organizations such as the National Association for Rehabilitation Providers and Agencies (NARA) and the National Association for the Support of Long Term Care (NASL), are here to support us!

All organizations have created action sites to enable effective communication with members of the US House.

American Association of Occupational Therapy

American Physiotherapy Association

American Speech-Language Pathology and Hearing Association

National Association of Rehabilitation Providers and Agencies

National Association for Long Term Care Support

Now is the time for SMART!

Thank you for your advocacy and your support for the profession. #FightTheCuts

For more information on the Medicare Physician Fee Schedule Final Rule, please visit: https://www.federalregister.gov/public-inspection/current

Renee kinder, MS, CCC-SLP, RAC-CT, is Executive Vice President of Clinical Services for Rehabilitation of the Broad River and a recipient of the 2019 APEX Excellence Award in the Writing category – Departments and regular columns. Additionally, she is the Professional Development Manager in Gerontology for the American Speech Language Hearing Association (ASHA) Gerontology Special Interest Group, is a member of the Community Faculty of the University of Kentucky College of Medicine, and is Advisor to the CPT on Current Procedural Terminology of the American Medical Association. ® Editorial panel. She can be reached at [email protected].

The opinions expressed in McKnight Long Term Care News guest submissions are those of the author and not necessarily those of McKnight Long Term Care News or its editors.


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